The International Safety Management (ISM) Code exists to make sure safety and environmental protection are built into how a ship is actually run, not just documented on paper. Passing an audit is a byproduct of a functioning system — not the goal itself. The following checklist covers the areas that tend to slip first when a safety management system isn't actively maintained.
1. A designated person ashore (DPA) who is actually reachable
The DPA is the link between shipboard operations and top management. If your crew doesn't know who the DPA is, or can't reach them promptly, the rest of the system doesn't matter much. Confirm contact details are current on board and that escalation paths are tested, not just documented.
2. Internal audits on a real schedule
Internal audits should happen at planned intervals — not squeezed in right before an external survey. A rushed internal audit tends to miss the same issues an external auditor will catch, which defeats the purpose.
3. Non-conformities that are tracked to closure
Recording a non-conformity is only half the job. Each one needs a corrective action, an owner, and a close-out date. A log full of open items with no follow-up is one of the first things an external auditor will flag.
4. Emergency preparedness drills that match the vessel's actual risks
Generic drills that don't reflect the vessel's specific equipment, trade, or crew composition tend to produce generic (and unhelpful) results. Drill scenarios should be reviewed periodically against the vessel's actual operating profile.
5. Familiarization records for every crew change
New crew joining without documented familiarization on safety and pollution-prevention procedures is a common finding. This record needs to be created at the time of joining, not reconstructed later.
6. Certificate and audit timelines tracked in advance
Interim, initial, and renewal audit windows should be tracked well ahead of their deadlines, with enough lead time to address any findings before a certificate is at risk.
7. A management review that changes something
Annual management reviews shouldn't be a formality. If the same findings show up review after review with no adjustment to procedures or resources, the review isn't doing its job.
Keeping all seven of these current is easier with a second, independent set of eyes on the documentation — particularly for owners managing more than one vessel or without a dedicated shore-side compliance team.